This policy statement applies to all staff, volunteers and other adults associated with our work at the Froebel Trust; anyone who is involved in taking photographs or film for us to use in our work; and anyone who is being photographed or filmed on behalf of the Froebel Trust.
The purpose of this policy statement is to:
- protect people whose images are taken for use by the Froebel Trust
- set out the overarching principles that guide our approach to images being taken and used
- to ensure that we operate in line with our values and within the law when creating, using and sharing images of people.
Legal framework
In addition to the legal framework relating to the protection and privacy of personal data (DPA 2018 and GDPR 2019), this policy sets out our assurances for safeguarding and respecting the rights and views of children.
Our assurances to you
Our policy has been drawn up on the basis of legislation, policy and guidance that seek to protect children in the four countries of the United Kingdom. We have used the guidance written by the NSPCC for our policy.
We believe that:
- children and young people should never experience abuse of any kind
- we have a responsibility to promote the welfare of all children and young people and to take, share and use images of children safely.
We recognise that:
- sharing photographs and films can help us celebrate successes and achievements and raise awareness of our organisation and Froebelian principles and practice
- the welfare of the people whose photographs we use is paramount
- everyone, including children, their parents and carers has a right to decide whether their images are taken and how these may be used, regardless of age, disability, gender reassignment, race, religion or belief, sex or sexual orientation
- consent to take images of children is only meaningful when children, their parents and carers understand how images will be used and stored, and are fully aware of the potential risks associated with the use and distribution of these images
- there are potential risks associated with sharing images of children online.
We will seek to keep people safe by:
- always asking for written consent before taking and using a person’s image. This includes sensitivity to a child’s wishes or intentions and consent from their parents or carers
- always explaining what images will be used for, how they will be stored and what potential risks are associated with sharing images
- making it clear that if a person withdraws consent for an image to be shared, it may not be possible to delete images that have already been shared or published
- changing the names of children whose images are being used in our published material whenever possible (and only using first names if we do need to identify them)
- never publishing personal information about individual children and disguising any identifying information (for example the name of their school or a uniform with a logo)
- making sure children, their parents and carers understand how images of children will be securely stored and for how long (including how we will control access to the images and their associated information)
- reducing the risk of images being copied and used inappropriately by:
- only using images of children in appropriate clothing (including safety wear if necessary)
- avoiding full face and body shots of children taking part in activities such as swimming where there may be a heightened risk of images being misused
- using images that positively reflect young people’s involvement in the activity.
Consent
When we gather images of people from a nursery, school or other setting for use by the Froebel Trust, we will always do this with the knowledge and consent of the person in charge of the setting and any adults who work in the setting whose images are taken.
When images are being taken, the children, young people, parents and carers must be made aware that photography / filming will take place and anyone with legal responsibility for children (parents/ carers) must have given their written consent beforehand.
We have prepared a form that must be used to gather written consent. We ask for written consent for use of their image and/ or participation in a video to be used by the Froebel Trust in perpetuity (in our printed publications, in our resources, on our website and on our social media platforms).
The completed forms must be passed to the person who takes the photographs / films. That person will be in charge of sending the forms to, or storing them securely on behalf of, the Froebel Trust.
Storing consent forms and images
All electronic images will be transferred to us and stored using secure methods, in accordance with our safeguarding policy and data protection law. We will never store images on unencrypted portable equipment such as laptops, memory sticks and mobile phones.
We will store copies of completed consent forms separately from images. This helps to protect the people in the images.
All electronic images will be kept in a protected folder with restricted access. Files will be date-stamped with the date when we receive the images. The original images or recorded footage will be stored on Froebel Trust systems for a maximum of 3 years after which they will be deleted permanently. If we keep hard copies of images, they will be stored in our locked safe and destroyed after 3 years.
Withdrawing consent
If you change your mind about consent for the Froebel Trust to use your image or the image of a child for whom you are the parent / legal guardian, please get in touch with us by email (office@froebeltrust.org.uk) or call us on 020 8878 7546. We will delete the image(s) from our systems and records.
If your image or your child's image has been used in one of our (downloadable) publications or films, we will remove it from our website. We will cease distribution of that publication or film (which contains your image/ your child's image). However, please be aware that we cannot recall any copies of the publication, resource or film which may have already been distributed or shared (prior to your withdrawal of consent); or if an image has already been shared via our social media channels.
Contacting us
If you have any questions, you can contact us by telephone, email or post.
The Chief Executive Officer of the Froebel Trust is Dr Sacha Powell. The Chair of Trustees is Mr Mark Neale. The person who coordinates our digital images is the Director of Communications, Flora Jenkins.
Complaints
If you have cause for complaint about the way that we have gathered, transferred, stored or used any images, you can write to us and / or you can contact the Information Commissioner’s Office (ICO) – www.ico.org.uk
Review
We are committed to reviewing all our policies annually. It will be reviewed no later than 30 June 2024.
